“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48 · 2019 · Supreme Court

696

citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT

50 ITR 1 · 1963 · Supreme Court

581

citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT

37 ITR 288 · 1959 · Supreme Court

570

citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull

87 ITR 349 · 1973 · Supreme Court

525

citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT

107 ITR 938 · 1977 · Supreme Court

477

citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.

208 ITR 465 · 1994 · High Court

427

citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT

172 ITR 250 · 1988 · Supreme Court

340

citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Surendra, Greater Noida vs. Ward 3(4) Noida, Noida

Appeal of the assessee is allowed for statistical purposes

ITA 727/DEL/2024[2012-13]Status: DisposedITAT Delhi18 Mar 2024AY 2012-13

Bench: Shri Kul Bharatassessment Year: 2020-21

Section 144Section 271(1)Section 271(1)(c)Section 68

completed the assessment at a total income of Rs. 39,00,000/- by adding the cash deposits of Rs. 39,00,000/- as unexplained money. The AO also initiated penalty proceedings u/s 271(1)(c) of the Act and vide penalty order dated 28.01.2022 levied a penalty

Kiranbhai Ranchhodbhai Patel, Kheda vs. The ITO, Ward-3 Now Ward-1, Nadiad

In the result, the appeal filed by the assessee is allowed

ITA 847/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad15 Mar 2024AY 2017-18

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita No. 847/Ahd/2023 धििाधरणवरध/Asstt. Year: 2017-2018 Kiranbhai Ranchhodbhai Patel, Income Tax Officer, Door No.67, Vs. Ward-3, Village Bhatera Anano Pol, Now Ward-1 Po Bhatera, Nadiad. Ta. Kathlal Kheda-387630. Pan: Avppp2903H

For Appellant: Shri Parin S Shah, A.RFor Respondent: Shri Sushil Kumar Katiar, Sr.D.R

Section 142(1)Section 69A

that the Ld. CIT(A), erred in confirming the addition made by the AO for Rs. 10,00,000/- on account of unexplained money by invoking the provisions of section 69A of the Act. 3. The assessee in the present case is an individual and claim to be engaged ... bank of the assessee, the source of which was not explained. Therefore, the AO treated the same as unexplained money u/s 69A of the Act and added to the total income of the assessee. 4. Aggrieved assessee preferred an appeal to the Ld. CIT(A) and submitted that the cash

Baji Shaik, Nuzvid vs. Income Tax Officer, Ward-3(1), Vijayawada

In the result, appeal of the assessee is allowed for statistical purpose

ITA 31/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam14 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.31/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2017-18) Baji Shaik Vs. Income Tax Officer 11/200-1 Near Fish Market Ward-3(1) Nuzvid, Eluru Vijayawada [Pan : Cjgps5389M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri Siva Ram Kumar, ARFor Respondent: Dr.Aparna Villuri, DR

Section 142(1)Section 144Section 147Section 148

bank account, inspite of various opportunities of being heard given to the assessee, the AO treated the amount of Rs.25,72,918/- as unexplained money u/s 69A of the Act, arrived at a total taxable income of Rs.28,56,600/- and initiated penalty proceedings u/s 271AAC of the Act separately

Kompella Rama Subrahmanya Sarma, Kakinada vs. Income Tax Officer, Ward-1, Kakinada

In the result, appeal filed by the assessee is allowed

ITA 22/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam14 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. No. 22/Viz/2024 (निर्धारण वर्ा / Assessment Year: 2017-18) Kompella Rama Subrahmanya Vs. Income Tax Officer, Sarma, Ward-2, Kakinada. Kakinada. Pan: Bqzpk 4682 G (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : Sri Gvn Hari, Ar प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 133(6)Section 143(2)Section 144Section 69A

record. Accordingly, the Ld. AO treated the cash deposits made by the assessee during the demonetization period of Rs. 15,26,000/- as unexplained money U/s. 69A r.w.s 115BBE of the Act and determined the total income at Rs. 19,64,360/- in the assessment order passed on 30/11/2019. Aggrieved ... assessee during the demonetization period. Therefore, the Ld. AO is right in his action in making the addition of Rs. 15,26,000/- as unexplained money U/s. 69A r.w.s 115BBE of the Act. The Ld. DR further submitted that before the Ld. CIT(A)-NFAC even though there

Sridhar Yarlagadda, Visakhapatnam vs. Income Tax Officer, Ward-3(2), Visakhapatnam

In the result, appeal filed by the assessee is dismissed

ITA 311/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam14 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.311/Viz/2023 (निर्धारण वर्ा / Assessment Year : 2017-18) Sridhar Yarlagadda, Vs. Income Tax Officer, Visakhapatnam. Ward-3(2), Pan: Abdpy4072 G Visakhapatnam. (अपीलधर्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधर्थी की ओर से/ Appellant By : None प्रत्यधर्थी की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: NoneFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 115BSection 133(6)Section 142(1)Section 143(2)Section 144Section 44ASection 68Section 69A

notices not furnished any submissions along with supporting documentary evidences. Accordingly, the Ld. AO treated the cash deposit of Rs. 15,42,000/- as unexplained money and made the addition U/s. 69A of the Act. 3. Aggrieved by the order of the Ld. AO, the assessee preferred an appeal before

Prasanth Jain Vijayakumar, Chennai vs. DCIT, Central Circle-1(2), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1126/CHNY/2023[2020-21]Status: DisposedITAT Chennai13 Mar 2024AY 2020-21

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1126/Chny/2023 िनधा"रण वष"/Assessment Year: 2020-21 Prasanth Jain Vijayakumar, Vs. The Deputy Commissioner Of 10/4, Kasi Chetty Lane, Sowcarpet, Income Tax, Chennai 600 079. Central Circle 1(2), Chennai 600 034. [Pan:Aaqpp7650M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 07.03.2024 घोषणा की तारीख /Date Of Pronouncement : 13.03.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-18, Chennai, Dated 28.07.2023 Relevant To The Assessment Year 2020-21. 2. Brief Facts Of The Case Are That The Assessee Filed His Original Return Of Income For The Assessment Year Under Consideration Admitting An Income Of ₹.4,88,690/-. A Search & Seizure Operation Under Section 132 Of The Income Tax Act, 1961 [“Act” In Short] Was Conducted At The Residential/Business Premises In The Case Of M/S. Golden Shelters Private

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT

Section 115BSection 132Section 143(2)Section 69A

seized. In the absence of explanation for the cash seized at the premise of the assessee, the Assessing Officer treated the same as unexplained money under section 69A of the Act and added to the total income of the assessee and taxed as per section 115BBE

Venkatesan, Chennai vs. ITO, Non Corporate Ward 8(1), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1332/CHNY/2023[2017-18]Status: DisposedITAT Chennai12 Mar 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.1332/Chny/2023 िनधा"रण वष" /Assessment Year:2017-2018 Shri Venkatesan, The Income Tax Officer, No.T/D 122, Koyambedu, V. Non Corporate Ward 8(1) Chennai 600092. Chennai. Pan: Aadpv 2269F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri Arv Sreenivasan, Irs, Addl. Cit. सुनवाई क" तारीख/Date Of Hearing : 12.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 12.03.2024 आदेश /O R D E R Per Mahavir Singh, Vp:

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri ARV Sreenivasan, IRS, Addl. CIT

Section 144Section 147Section 148Section 69A

assessee failed to file the return of income, the ld. Assessing Officer added a sum of Rs.2,77,93,600/- as unexplained money u/s.69A of the Act to the total income of the assessee. Aggrieved, assessee preferred an appeal before the ld. CIT(A). 3. The CIT(A) also confirmed

Amit Nagesh Shinde, Mumbai vs. Income Tax Ward-26(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3284/MUM/2023[2016-17]Status: DisposedITAT Mumbai12 Mar 2024AY 2016-17

Bench: Us, Reads As Under:-

Section 131Section 133(6)Section 143(3)Section 69ASection 69C

lenders. Hence, credit worthiness and genuineness of the transaction cannot be proved. Accordingly, amount of Rs.10,62,534/- was added u/s.69A as unexplained money. 4. Further, on perusal of the profit and loss account, he noted that assessee has claimed financial expenses of Rs.4,62,944/- and at the same

Syed Karimulla, Rajampet vs. Income-Tax Officer, Ward-1, Cuddapah

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 149/HYD/2024[2017-18]Status: DisposedITAT Hyderabad11 Mar 2024AY 2017-18

Bench: Shri Laliet Kumarassessment Year: 2017-18 Syed Karimulla, Nandalur, Vs. The Income Tax Officer, Rajampet, Ward – 1, D.No.5-98-C, C/O.Shaik Cuddapah Mastan Vali, Near Nandalur Bus Stand, Andhra Pradesh – 516510. Pan : Fddps8691Q (Appellant) (Respondent) Assessee By: Shri Abhiroop Bhargav, C.A. Revenue By: Shri B. Yadagiri, Sr.Ar Date Of Hearing: 07.03.2024 Date Of Pronouncement: 11.03.2024

For Appellant: Shri Abhiroop Bhargav, C.AFor Respondent: Shri B. Yadagiri, SR.AR

Section 115Section 139(1)Section 142(1)Section 144Section 234ASection 234BSection 69ASection 80CSection 80T

That on the facts and circumstances of the case, the Ld.AO/ CIT(A) erred in carrying out an addition towards unexplained money under Section 69A of the Act amounting to 3. That on the facts and circumstances of the case, the Ld.AO/ CIT(A) erred in not allowing deduction under ... sources for the old SBN (Specified Bank Notes) put into Bank Account, the remaining amount of Rs.7,00,000/- was deemed as unexplained money u/s 69A of the Income Tax Act, 1961 which was taxed u/s 115 BBE of the Act @ 60%. Thus, Assessing Officer completed the assessment interalia making

Alchemist Touchnology, New Delhi vs. ACIT, Central Circle-20, New Delhi

ITA 1689/DEL/2022[2013-14]Status: DisposedITAT Delhi11 Mar 2024AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganeshalchemist Touchnology, Vs. Acit, Building No. 23, Nehru Central Circle-20, Place, Alchemist House, Delhi South Delhi-110019 (Appellant) (Respondent) Pan:Aaica1617Q Assessee By : Shri N. K. Lal, Ca Revenue By: Shri Zafarul Haque Tanweer, Cit Dr Date Of Hearing 10/01/2024 Date Of Pronouncement 11/03/2024

For Appellant: Shri N. K. Lal, CAFor Respondent: Shri Zafarul Haque Tanweer, CIT DR

Section 132Section 153ASection 153CSection 153DSection 245D(1)Section 69

assessee sent for the purpose of obtaining funds through FDI route to avoid tax incidence which have been introduced in its books. Such unexplained money introduced in its books through FDI route is liable for addition u/s 68 of the Act since the money has been sent to secure such

Bhagvanjibhai Somabhai Patel, Vadodara vs. The Income Tax Officer, Ward-1(3)(1), Vadodara

ITA 746/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad08 Mar 2024AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(2)Section 147Section 148Section 234ASection 271(1)(b)Section 271(1)(c)Section 271FSection 69A

Assessing Officer also quoted another Bank Account No. 92420100003729 with Bank of Baroda. Thus the Assessing Officer treated the entire cash deposit as unexplained money u/s. 69A of the Act and demanded tax thereon. The Assessing Officer also charged interest I.T.A No. 746/Ahd/2023 A.Y. 2013-14 Page No 3 Bhagvanjibhai

ACIT, Circle CC 15, New Delhi vs. Alka Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1864/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR

Section 153ASection 69

1864/Del/2021 25 CO Nos. 25 & 28/Del/2022 Yash Pal & Alka Mendiratta "Section 69A, read with section 292C, of the Income-tax Act, 1961 - Unexplained money (Presumptive addition) - Assessment year 2009- 10 - Assessee sold a property and derived long-term capital gain - During search, diary of a third party was seized from

ACIT, CC-15, New Delhi vs. Yash Pal Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1863/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR

Section 153ASection 69

Khaja Mannan Ullaha, Hyderabad vs. Income Tax Officer, Ward-1, Siddipet

In the result, the appeal of the assessee is partly allowed

ITA 127/HYD/2024[2017-18]Status: DisposedITAT Hyderabad07 Mar 2024AY 2017-18

Bench: Shri Laliet Kumarassessment Year: 2017-18 Khaja Mannan Ullaha, Vs. The Income Tax Officer, Hyderabad. Ward –1, H.No.17-1-B/18/1, Siddipet, Santosh Nagar Colony, Telangana – 502103. Near Sadhana College, Saidabad, Telangana – 500059. Pan : Axdpk2597E. (Appellant) (Respondent) Assessee By: Sri A. V. Raghuram, C.A. Revenue By: Sri B. Yadagiri, Sr.Ar Date Of Hearing: 07.03.2024 Date Of Pronouncement: 07.03.2024

For Appellant: Sri A. V. Raghuram, C.AFor Respondent: Sri B. Yadagiri, SR.AR

Section 115BSection 133(6)Section 139Section 142(1)Section 144Section 69A

facts and in law. 2. The ld. CIT(A) erred in confirming the addition of Rs.17,50,000/- made by the AO as unexplained money u/s.69A of the Act.” 3. The brief facts of the case are that the assessee had made cash deposits aggregating to Rs.13,37,500/- into

Surender Kumar Jain, Delhi vs. ACIT, Central Circle-14, New Delhi

In the result, the appeals of the assessee for AY 2016-17 and AY

ITA 1315/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Mar 2024AY 2017-18

Bench: Shri Dr. Brr Kumar & Ms. Astha Chandra

For Appellant: Shri P. Ray Choudhary, AdvocateFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 132Section 143(3)Section 153CSection 69A

ledger or any other material to support this view. Further, there is no evidence on record to show that the alleged transactions refer to ‘unexplained money’ as held by the Ld. CIT(A) in AY 2017-18. 8. The Ld. Sr. DR relied on the orders of the Ld. AO/CIT ... confirmed the impugned addition in AY 2016-17 under section 69C as unexplained expenditure and in AY 2017-18 under section 69A as unexplained money. In our view the impugned addition made by the Ld. AO in both the AY(|s) is not sustainable because it is based on mere

Surender Kumar Jain, Delhi vs. ACIT, Central Circle-14, New Delhi

In the result, the appeals of the assessee for AY 2016-17 and AY

ITA 1314/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Mar 2024AY 2016-17

Bench: Shri Dr. Brr Kumar & Ms. Astha Chandra

For Appellant: Shri P. Ray Choudhary, AdvocateFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 132Section 143(3)Section 153CSection 69A

Jayaraj Gunasekaran, Chennai vs. ITO, Non Corporate Ward 10(1), Chennai

In the result, the appeal of the assessee is allowed for statistical purposes only

ITA 1193/CHNY/2023[2017-18]Status: DisposedITAT Chennai06 Mar 2024AY 2017-18

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.1193/Chny/2023 िनधा(रण वष( /Assessment Year: 2017-18 Jayaraj Gunasekaran, The Income Tax Officer, Old No.18, Reddy Street, Vs. Non Corporate Ward-10(1), Villivakkam, Chennai. Chennai – 600 049. [Pan: Afapg-7047-L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Harshavardhan, Advocate ""यथ" क" ओर से /Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 15.02.2024 घोषणा क" तारीख /Date Of Pronouncement : 06.03.2024

For Appellant: Shri Harshavardhan, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT

Section 142(1)Section 143(2)Section 144Section 148Section 148ASection 69A

during the demonetization period. Therefore, the ld. AO vide order dated 08-05-2023 treated the aforesaid amount of Rs. 30,98,000/- as unexplained money u/s 69A of the Act and added to the total income of the assessee. :- 4 -: Being aggrieved, the assessee filed 1st appeal before

Bharat Bhushan, Ghaziabad vs. ITO, Ward- 1(5), Ghaziabad

The appeal of the assessee is dismissed

ITA 4102/DEL/2018[2009-10]Status: DisposedITAT Delhi05 Mar 2024AY 2009-10

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2009-10

Section 147Section 148Section 48Section 69

addition of Rs. 59,05,000/- made on account of cash deposited by the assessee in the Punjab National Bank, which was considered unexplained money u/s 69 of the Act. As such the assessment before learned AO was concluded u/s 147/144. Learned CIT(A) had allowed the additional evidence

Mahendrakumar Khetmal Jain, Nandurbar vs. Income Tax Officer, Ward-1, Dhule

Appeal is partly allowed in above terms

ITA 1375/PUN/2023[2017-18]Status: DisposedITAT Pune04 Mar 2024AY 2017-18

Bench: Shri Satbeer Singh Godara

For Appellant: Smt. Deepa KhareFor Respondent: Shri Basavaraj Hiremath

Section 143(3)Section 69A

cash deposited in SBN during the demonetization period of Rs.11,19,000/- claimed to be pertaining to family members is held to be the unexplained money of the appellant himself. 4 ITA.No.1375/PUN./2023 Accordingly, the addition of Rs.11,19,000/- is upheld. The Ground of appeal raised is partly

Naseem Ahmad, Lucknow vs. ITO Range-3(2), Lucknow

In the result, the appeal of the assessee stands partly allowed for statistical purposes

ITA 363/LKW/2023[2017-18]Status: DisposedITAT Lucknow29 Feb 2024AY 2017-18

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2017-18 Naseem Ahamad, Vs. The Income Tax Officer, H.No. 57, Bhakhamau, Behta, Office Of The Income Tax Bakshi Ka Talab, Officer, Range-3(2), Lucknow. Lucknow. Pan: Apqpa 4484H (Appellant) (Respondent) Appellant By Shri Shubham Rastogi, Advocate Respondent By Shri Sanjeev Krishna Sharma, Addl. Cit (Dr) Date Of Hearing 23/01/2024 Date Of Pronouncement 29/02/2024

Section 115BSection 144Section 44ASection 69A

impugned amount in its Gross Receipts and paid tax thereon, further addition made by the A. O. by again treating the same cash as unexplained money will amount to double addition in the hands of the assessee. 13. The Ld. C.I.T. (A) failed to appreciate that cash has been deposited